Consumer Compliance Outlook > 2026 > First Issue 2026

Consumer Compliance Outlook: First Issue 2026

2024 Aggregate Consumer Complaint Data for Federal Reserve–Supervised Institutions

By Kenneth J. Benton, Principal Consumer Regulations Specialist, and Nicholas Smuz, Legal Intern, Federal Reserve Bank of Philadelphia

Federal Reserve staff identify and investigate possible violations of consumer protection laws through the Federal Reserve System’s consumer complaint and consumer inquiry programs. Through these programs, staff answer consumers’ questions, explain consumer rights under federal law, investigate complaints against entities supervised by the Federal Reserve, and refer complaints about other entities to the appropriate agency. Consumer complaints are a critical component of the risk-focused supervisory program. The Federal Reserve uses data on consumer complaint activity in its supervisory processes when monitoring financial institutions, scoping and conducting examinations, and analyzing applications.

—Board of Governors of the Federal Reserve System¹

The Federal Reserve System (Federal Reserve) is the primary federal regulator for the 705 state-chartered banks (as of December 2025) with membership in the Federal Reserve (known as state member banks or SMBs).² The Federal Reserve also has supervisory responsibility for bank holding companies and certain other financial entities.³

To ensure compliance with the consumer protection laws it is charged with enforcing, the Federal Reserve collects, analyzes, monitors, and responds to consumer complaints it receives against SMBs and selected nonbank subsidiaries of bank holding companies. The complaint data inform the Federal Reserve’s understanding of consumer protections risks and issues. Complaints against an institution outside of the Federal Reserve’s jurisdiction are forwarded to the agency with supervisory authority over that institution. Complaint trends are reported to Congress annually.⁴

The Federal Reserve’s complaint data can help financial institutions by identifying common consumer issues in banking of which an institution may not be aware. An institution could review its complaints logs to see where its complaint data align with the Federal Reserve’s data, test its compliance risk management procedures and controls in these areas, and provide suggestions to its customers to address pain points. For example, inaccurate information in a consumer’s credit report is a common complaint topic in the Federal Reserve’s data and in the complaint data of the Federal Trade Commission (FTC)⁵ and the Consumer Financial Protection Bureau (CFPB).⁶ If an institution found its customers were also filing complaints on this issue, it could consider posting information on its website and on periodic statements for credit products explaining the procedures to dispute information in a credit report with the three national consumer reporting agencies or with the furnisher directly.

In this article, we discuss the themes and trends of the 8,355 consumer complaints the Federal Reserve received, investigated, and closed in 2024 for the institutions under its supervisory authority (Table 1). Additionally, we highlight the bank products that received the most complaints as well as high-volume complaint issues and actions taken in response to a complaint investigation. We conclude with lessons community banks may glean from the complaint data themes to enhance their overall consumer compliance risk management programs.

COMPLAINT PRODUCTS MIX

Of the total complaints investigated and closed in 2024, the products receiving the highest volume of complaints were deposit accounts (57 percent), prepaid cards (25 percent), and credit cards (14 percent). All other types of bank products and services accounted for less than 10 percent of complaint volumes (see Table 2; categories are in bold).

2024 TOP 10 COMPLAINT CATEGORIES

Here are examples of the common types of complaint allegations within each category.

Restricted/Blocked Accounts

Most complaints in this category involved prepaid cards and deposit accounts, and a high percentage of these involved mobile banking services. Consumers alleged that access to their accounts was blocked because they reported identity theft or unauthorized transactions. Additionally, several consumers stated they experienced significant hardship when accounts were blocked over extended time frames, especially when the accounts contained wages or government benefit payments.

Fraud/Forgery

A large percentage of fraud/forgery complaints involved identity theft affecting deposit, credit card, and prepaid card accounts. Consumers reported accounts were opened without their authorization (including receiving unsolicited debit and credit cards) and fraudulent activity on existing accounts. In several instances, consumers noted they were victims of scams, data breaches, or counterfeited and altered checks.

Error Resolution

Complaint allegations primarily related to deposits and prepaid cards, and a substantial majority of these complaints involved mobile banking services. Generally, consumers disputed unauthorized electronic account withdrawals. Consumers often noted that the unauthorized withdrawals resulted from fraud and scams, disputed purchases, or person-to-person transfer errors. Consumers also disputed unanticipated bank fees that they stated were applied in error.

Funds Availability

More than half of the complaints in this category involved bank prepaid cards and mobile banking services. Consumers often alleged they were not given timely access to tax refunds and other specific types of deposits or could not activate prepaid cards. Some complaints alleged that consumers’ funds were held because of bank concerns about potentially fraudulent or suspicious activity by the consumer or a third party. Consumers also reported delays in completing bank error resolution investigations that resulted in funds not being available for unreasonably long periods.

Credit Reporting

Most of the credit reporting complaints were grouped into two categories:

• allegations that banks failed to report, or misreported, data to the consumer reporting agencies, and
• requests for the consumer reporting agencies to remove accounts and inquiries that resulted from fraud or identity theft.

Fees/Terms/Rates

This category includes general complaints about all types of deposit and loan fees, rates, and terms. Complaints involved a wide range of bank products and services but were primarily related to credit cards and mobile banking. This category also included complaints alleging that banks failed to honor specific account terms and promotional offers. The complaints involved fees for credit card activation, overdrafts, late and returned items, account maintenance, and automated teller machine use.

Account Closures

Complaints in the account closure category were largely related to deposit products and credit cards. In several complaints, consumers alleged accounts were not closed when requested, accounts were closed unexpectedly, or closing fees were improperly assessed. Consumers also reported that the remaining funds in closed accounts were not returned in a timely manner and that rewards, bonuses, and other promotions were not honored after accounts were closed.

Applications/Account Openings

Application/account opening complaints generally involved deposits and credit cards. Complaint allegations included banks not approving consumers’ requests to open loan or deposit accounts and that, after accounts were opened, account terms differed from what was disclosed or expected. Moreover, consumers disputed bank account opening policies, procedures, and disclosures. Included in this category were complaints about card activation policies and adverse action notices.

Debt Validation

Most complaints in this category noted that their bank or a debt collector erroneously reported a delinquent loan to consumer reporting agencies in their name when, in fact, the consumer did not apply for or otherwise become responsible for the loan.

Inability to Repay

This category involved complaints in which consumers sought assistance for a loan they could not repay because they were experiencing financial hardship.

INVESTIGATION FINDINGS

In most cases, the Federal Reserve Bank with supervisory responsibility for the bank for which the consumer filed the complaint will notify the consumer in writing of the investigation results. Some investigations concluded that banks violated federal consumer protection laws and regulations or that bank errors unrelated to regulatory violations occurred. If applicable, banks were ordered to provide restitution to the consumer for violations.⁷ In other cases, the Reserve Bank determined the bank complied with federal consumer protection laws and regulations. Finally, when a complaint concerned an institution for which another federal regulator had jurisdiction, the complaint was referred to that agency to investigate.

While the number of complaints alleging violations and bank errors increased from 6,012 in 2023 to 8,355 in 2024, the number of complaint investigations concluding a violation or error occurred remained low. Less than 1 percent of the 8,355 complaint investigations found regulatory violations or bank errors.

Table 3 shows the top violations cited in response to consumer complaints.

As Table 3 shows, the largest number of cited violations resulting from complaint investigations over the past five years involved Regulation E error resolution procedures for deposit accounts and prepaid cards. In 2024, 66.2 percent of the cited violations involved Regulation E complaints for restricted/blocked accounts, fraud/forgery, funds availability, and error resolution. Examples of funds availability complaints resulting from bank errors were customers being unable to access specific types of deposits, such as tax refunds and government benefit payments. Some complaints involved customers being unable to access funds on prepaid cards.

Over the years, Consumer Compliance Outlook (CCO) has published many articles on Regulation E compliance requirements and sound practices to mitigate risk:

• Scott Sonbuchner, “Error Resolution Under Regulation E: Examiner Insights and Common Violations” (Third Issue 2025)
• Kenneth Benton, “Consumer Liability for Unauthorized Transactions Under the Electronic Fund Transfer Act and Regulation E” (Third Issue 2025)
• Kenneth Benton, “Error Resolution Procedures Under the Electronic Fund Transfer Act and Regulation E” (Third Issue 2025)
• Kenneth Benton, “The Electronic Fund Transfer Act, Regulation E, and Instant Payment Services” (Third Issue 2025)
• Scott Sonbuchner, “Error Resolution and Liability Limits for Prepaid Accounts and Foreign Remittance Transfers” (Second Issue 2021)
• Scott Sonbuchner, “Error Resolution and Liability Limitations Under Regulations E and Z: Regulatory Requirements, Common Violations, and Sound Practices” (Second Issue 2021)
• Kenneth Benton, “Credit and Debit Card Issuers’ Obligations When Consumers Dispute Transactions with Merchants” (First Issue 2016)

CONCLUSION

The 2024 complaint data themes and trends in this article provide useful compliance risk management information for banks, including these observations:

• Customer service. For Regulation E error resolution complaints, consumers stated that unresponsive bank customer service and improper error resolution practices prompted them to contact Federal Reserve Consumer Help for assistance. The volume of investigations finding regulatory violations from these complaints underscores, from a risk-focused perspective, the importance of ensuring that financial institutions are complying with Regulation E’s error resolution requirements.
• Consistent documentation. Complaint issues often arose from consumers disputing when deposited funds would be available and the rates, terms, and conditions of loan and deposit accounts. These issues show the need for clarity, accuracy, and consistency with advertisements, contracts, and disclosures.

Specific issues and questions should be raised with your primary regulator.

Additional Resources

• Scott Sonbuchner, “The Benefits of a Formal Complaint Management Program,” CCO (Second Issue 2024)
• Andrea Sovich, “Enhancing the Compliance Management Program with Complaint Data,” CCO (Second Issue 2024)
• Alinda Murphy, “Consumer Complaints 2023: A Review of Federal Reserve Data,” CCO (Second Issue 2024)
• “Complaints as a Supervisory and Risk Management Tool,” Outlook Live webinar (August 29, 2018)

ENDNOTES

¹ See “Consumer Compliance,” Board of Governors of the Federal Reserve System, https://www.federalreserve.gov/supervisionreg/consumer-compliance.htm.

² The standards for state chartered banks to become a member of the Federal Reserve System are set forth in Regulation H, 12 C.F.R. §208.3. As part of this supervisory authority, the Federal Reserve examines SMBs for compliance with consumer protections laws. The Dodd–Frank Act provides that the Consumer Financial Protection Bureau (CFPB) examines SMBs with assets of $10 billion or greater for compliance with “federal consumer financial laws,” a term defined in 12 U.S.C. §5481(14). 12 U.S.C. §5515(b)(a)). Even for institutions with assets of $10 billion or greater, enforcing compliance with certain consumer protection laws outside of the CFPB’s jurisdiction remains with the Federal Reserve, including the Fair Housing Act, the Community Reinvestment Act, the Flood Disaster Protection Act of 1973, Section 5 of the Federal Trade Commission Act, the garnishment rule (31 C.F.R. Part 212), the Servicemembers Civil Relief Act, and the Expedited Funds Availability Act.

³ See Report to Congress: 111th Annual Report of the Board of Governors of the Federal Reserve System at pp. 86–87.

⁴ Ibid.

⁵ The FTC’s top consumer complaints are available in its Consumer Sentinel Network Data Book 2024, p. 8.

⁶ The CFPB’s top consumer complaints are available in its Consumer Complaint Database.

⁷ Some laws, such as the Truth in Lending Act, 15 U.S.C. §1601 et seq., require that restitution be provided for certain violations. See 15 U.S.C. §1607(e). In addition, the federal banking agencies have authority under §8(b)(6)(a) of the Federal Deposit Insurance Act to order restitution for violations of applicable law if the depository institution was unjustly enriched or the violation involved a reckless disregard of a law, regulation, or prior order. See 12 U.S.C. §1818(b)(6)(a)(i)–(ii).